1 APPROACHING DEADLINES
| Quarter 2 2025 | 4 April 2025 | Deadline for Irish fund management companies to submit their completed "Registers of Information" on all contractual arrangements with ICT third party service providers under DORA to the Central Bank of Ireland (Central Bank). |
| 16 April 2025 | ESMA is due to deliver (i) its proposed regulatory technical standards on the characteristics of liquidity management tools (LMT) and (ii) its proposed guidelines on the selection and calibration of LMTs under AIFMD II to the European Commission. | |
| 24 April 2025 | Updated guidelines on stress test scenarios under the MMF Regulation begin to apply. See Section 5.1 below for further details. | |
| 21 May 2025 | The ESMA fund naming guidelines begin to apply to all in-scope funds established before 21 November 2024. | |
| 30 May 2025 | Deadline for filing the fund profile return for all Irish authorised sub-funds with the Central Bank. | |
| 30 June 2025 | Deadline for fund management companies managing Irish UCITS ETF to ensure compliance with the supervisory expectations set down by the Central Bank in its the Central Bank in its Dear Chair Letter published in November 2024. | |
| 30 June 2025 | Fund management companies which (i) are obliged due to their size; or (ii) which have chosen to report on the principal adverse impacts of investment decisions on sustainability factors under Article 4 of the SFDR must publish a full PAI statement (which for the first time must include historical comparisons against last year's PAI report) on their website on or before this date. | |
| Quarter 2 2025 | The Central Bank is expected to publish a consultation paper on proposed changes to its AIF Rulebook to address the implementation of AIFMD II into the Irish regulatory framework and may also incorporate various provisions to further enhance the product offering for funds implementing private market strategies. | |
| Quarter 2 2025 | The European Commission is due to publish a legislative proposal to reform the existing EU Securitisation Regulation. See Section 10.2 for further details. | |
| H2 2025 | July 2025 | ESMA is due to provide its technical advices to the European Commission on its proposed reform of the UCITS Eligible Assets Directive1. |
| 2 August 2025 | Rules on governance and the obligations for general-purpose AI models under the EU AI Act become applicable. | |
| Quarter 3 2025 | The European Commission is expected to adopt measures to create a blueprint for EU savings and investment accounts or products aimed at improving retail participation in EU capital markets. See Section 10.1 below for further details. | |
| Quarter 4 2025 | The European Commission is scheduled to publish its proposal to reform the SFDR regime in Quarter 4 2025. | |
| Quarter 4 2025 | The European Commission is expected to publish a legislative proposal to transfer certain supervisory tasks from individual national competent authorities to EU-level supervision for asset management groups with significant cross-border activities. See Section 10.1 below for further details. | |
| Quarter 4 2025 | The European Commission is expected to publish a legislative proposal aimed to improve the cross-border distribution of EU-authorised funds across the EU. See Section 10.1 below for further details. | |
| Quarter 4 2025 | The European Commission is expected to publish a legislative proposal to reduce operational barriers faced by asset managers operating as a group structure across multiple EU Member States. See Section 10.1 below for further details | |
| 2026 | 24 March 2026 | The Central Bank's revised Consumer Protection Code begins to apply. See Section 3.2 below for further details. |
2 UCITS & AIFMD
2.1 Central Bank of Ireland publishes new Q&A on AIFMD
On 7 March 2025, the Central Bank published a revised version of its AIFMD Questions & Answers (Q&A).
In the Q&A, the Central Bank has provided clarity on the ability of an Irish QIAIF to act as guarantor for third parties as well as providing guidance on the scope of two of the existing rules imposed by it on Irish domiciled loan-originating AIFs.
In the Q&A, it has confirmed that:
- it is possible for an Irish QIAIF to provide a guarantee in respect of investments/or intermediate vehicles for such investments in which the QIAIF has a direct or indirect economic interest provided that certain conditions outlined in the Q&A are satisfied.
- an Irish domiciled loan-originating QIAIF may originate a loan to a borrower where that borrower has the intention of obtaining a controlling interest in another company.
- the definition of "financial institution" in the Central Bank's AIF Rulebook for the purposes of its prohibition of Irish loan-originating QIAIFs lending to "financial institutions" is aligned with that set out in the new AIFMD II loan origination rules.
A copy of the Q&A is available here.
A Dillon Eustace briefing which provides a detailed analysis of the clarifications provided by the Central Bank in the Q&A is available here.
2.2 ESMA publishes two new Q&A on AIFMD
On 6 January 2025, ESMA published two new Q&A on AIFMD.
The first Q&A confirms that AIFMs are not permitted to delegate portfolio or risk management to non-supervised undertakings established outside of the EU.
The second Q&A published by ESMA confirms that AIFMs are not permitted to hold client money, noting that such a service is not compatible with Article 6(4)(b)(ii) of AIFMD. ESMA also confirms that this position will not change in light of the legislative amendments introduced under AIFMD II2.
A copy of the ESMA Q&A on delegation of portfolio or risk management to non-supervised undertakings established outside of the EU is available here.
A copy of the ESMA Q&A on the ability of AIFMs to safekeep client monies is available here.
2.3 ESMA announces delay in publication of its technical advices on reform of the UCITS Eligible Assets Directive and RTS on openended loan originating AIFs
In June 2023, the European Commission wrote to ESMA requesting it to carry out an assessment of the implementation of the UCITS Eligible Assets Directive3 in EU Member States, provide it with recommendations on how it should be revised to keep it in line with market developments.
On 3 March 2025, ESMA wrote to the European Commission advising that due to a prioritisation of its deliverables for 2025, its technical advices setting out proposed reforms of the UCITS Eligible Assets would be delivered to the European Commission in July 2025, three months later than the scheduled date of April 2025.
The letter also confirmed that there would be a six-month delay in the publication of its technical advices to the European Commission on conditions to be satisfied by open-ended loan originating AIFs under AIFMD II, indicating that these technical advices will now be delivered by ESMA in October 2025.
A copy of the letter from ESMA to the European Commission is available here.
3 CENTRAL BANK OF IRELAND
3.1 Central Bank publishes Supervisory & Regulatory Outlook Report
On 28 February 2025, the Central Bank published its second Regulatory & Supervisory Outlook (Report) in which it sets out its perspective on key trends and risks, as well as outlining its supervisory priorities across the whole of the financial sector for the next two years.
The Report has been brought to the specific attention of all senior management teams of Irish regulated firms via a "Dear CEO" letter issued by the Central Bank on the same day (Letter).
In the Report, the Central Bank identifies key risks faced by the Irish funds sector which include:
- liquidity and leverage risks
- asset valuation and market risks
- operational risks and resilience
- sustainable finance
- data, AI and modelling risks
- strategic risk and adapting to structural change
The Report also outlines the Central Bank's current supervisory priorities and key regulatory initiatives relevant to the funds sector.
A copy of the Report is available here.
A copy of the Letter is available here.
A Dillon Eustace briefing which provides a detailed overview of the Report and suggested actions which should be considered by Irish fund management companies to address the supervisory expectations of the Central Bank outlined in the Report is available here.
| Key Action Points | As suggested by the Central Bank in the Report, Irish fund management companies should review the Report and incorporate its contents, as well as other communications issued by the Central Bank such as Dear CEO letters, into their ongoing work and decision-making. |
3.2 Central Bank publishes its revised Consumer Protection Code
On 24 March 2025, the Central Bank published a newly revised Consumer Protection Code (Revised Code) following a public consultation process. The Revised Code will be fully operational from 24 March 2026 and will replace the existing Consumer Protection Code 2012.
The Revised Code comprises:
- Central Bank Reform Act 2010 (Section 17A) (Standards For Business) Regulations 2025 (Standards for Business Regulations); and
- Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025 (Consumer Protection Regulations).
Subject to certain limited exceptions, the Standards for Business Regulations apply to all Irish regulated entities and set out governance, resource and risk management requirements as well as the applicable conduct standards which must be complied with by in-scope firms.
The Consumer Protection Regulations set out cross-sectoral requirements applying across all sectors which include for example requirements relating to digitalisation, informing effectively, advertising and complaints resolution. Importantly, the requirements set down in the Consumer Protection Regulations only apply to Irish regulated entities falling within the scope of the regulations in respect of business conducted with "consumers" within the meaning of the Revised Code which includes individuals and small businesses.
A copy of the Standards for Business Regulations is available here.
A copy of the Consumer Protection Regulations is available here.
Relevant guidance published by the Central Bank on the Revised Code is accessible here.
For a more detailed analysis of the Revised Code, please access our briefing on the topic which is available here.
| Key Action Points | Irish fund management companies and Irish domiciled corporate funds should analyse the implications of the Revised Code on their existing frameworks and identify any actions that may need to be taken to ensure compliance, where applicable, with the Revised Code by 26 March 2026. |
Footnotes
1 Directive 2007/16/EC
2 Directive (EU) 2024/927 which must be transposed into Irish law by 16 April 2026
3 Directive 2007/16/EU as amended
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Originally published 11 April 2025
Deadline for Irish fund management companies to submit their completed "Registers of Information" on all contractual arrangements with ICT third party service providers under DORA to the Central Bank of Ireland (Central Bank).
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
